LOTO 10 Important Procedural Dangers that are Avoidable

worker applying lockout tagout

We already know the significance of having a lockout and safety tag system in place to protect the safety of the employees, but what are some of the common problems businesses encounter with their hazardous energy control procedures?

It doesn’t matter what industry you look at; everyone has horror stories and near-miss stories about lock out /tag out procedures failing or almost failing. Despite our best efforts, the best training, the strongest lockout program, and safety equipment, sometimes accidents can still happen.

Compliance with OSHA Standard Today

Over the last thirty years, businesses across the United States have come a long way in improving their lockout/tagout procedures, including lockout devices. It could be due to the increase of awareness surrounding lockout/tagout or because more businesses are complying with OSHA standard 29 CFR 1910.147.

OSHA estimated that the lockout/tagout standard could prevent more than 100 fatalities and protect workers from thousands of non‐fatal injuries every year. Below we’re going to take a look at ten of the most common red flags when conducting lockout/tagout procedures.

10 Most Common Problems with Lockout and Tag Procedures

1. Lack of adequate tagout/lockout procedures

You need to consider that each machine and piece of equipment is unique and may require different tagout lockout procedures. Having a blanket tagout/lockout procedure is great, but if it doesn’t apply to all of your machinery then there could be gaps in the energy control procedure. Plus, errors in the application of lockout tagout safety devices could further lead to more unwanted accidents.

Furthermore, OSHA Standards require a specific written procedure when a single lockout device is insufficient to ensure that the machine has zero stored energy.

2. Failure to train all employees

Most companies focus on training their employees that deal directly with the equipment, those applying locks and tags known as ‘authorized employees’ and also the operators of equipment known as ‘affected employees’, but did you know there’s also a third category that also requires training?

This group is classified as ‘all other employees’ and also needs to be aware of hazardous energy control procedures, including lockout/tagout. Even though they aren’t going to be operating or working on the energy source, if they are in the general location of the hazardous energy sources, they still need to be trained.

3. Incorrect use of tags and locks

There are 4 types of general safety tags: Danger, Warning, Caution, and Notice. Each of them has its own purpose as well. Unfortunately, sometimes danger tags or lockout tags are used as general information or warning tags.

All ‘Danger Do Not Operate’ tags should only be used for the purpose intended. Otherwise, it can degrade the seriousness and importance of the tag. If the situation requires alternative tags for communicating hazards other than hazardous energy, then they should be implemented separately to the tagout devices.

4. Incorrect use of locks

Just like tagout devices, lockout locks should never be used to lock tool boxes, lockers, cabinets, cages, or for any other purpose other than what they are intended for. As with the tags above, any use other than their intended use could degrade the importance of lockout locks.

5. Working under other people’s locks and tags

The best practice for employees conducting servicing or maintenance activities on equipment is to apply locks and tags in accordance with OSHA Standard 1910.147 (Control of Hazardous Energy). At the same time, these lockout devices should only be under the sole control of the authorized employee doing the energy control procedures. Allowing another worker to be in charge of applying lockout locks and tags creates more possibilities for errors or mistakes to be made.

While there are some exceptions, such as when the authorized employee who applied the lockout or tagout device is unavailable to remove it, the lockout device may be removed but only with the employer's approval. This is provided that particular removal processes and training have been devised, recorded, and included in the employer's energy control program.

6. Failing to identify all energy sources

All energy sources need to be identified when applying locks and tags. If you fail to identify alternative activation or control points, then hazardous energy from the equipment won’t be 100% isolated. Some of the most overlooked energy sources are separate circuits running to a machine, delivery of energy from an overhead crane or adjacent conveyor, and gravity and kinetic energy.

All hazardous energy sources may be assessed properly if a hazard identification worksheet is in place. It should list the tasks and hazards caused by an unintended starting, inadvertent movement, or energy release. It should also specify the sort of energy that must be controlled.

7. Lack of annual reviews and audits of procedures

OSHA requires annual audits and reviews of lockout/tagout procedures. This is conducted to verify that processes are not just effective, but that employees understand and are following the procedures correctly. Audits and reviews can help to identify any problems or issues with procedures before an accident occurs.

8. Minor routine maintenance and changes compared to servicing maintenance

If it’s only something minor like a quick clean or changing a blade, are your employees following the lockout/tagout procedures, or are they taking shortcuts? Everyone must understand that the risks are the same regardless of whether or not it’s just a ‘five-minute’ job or a five-hour shutdown.

9. Never assume that everything is okay

Just because you’ve never had any lockout/tagout accidents, it doesn’t mean that you’re not going to. Assuming that everything is going great just because there have been no accidents, doesn’t mean that it is. Audits and reviews of policy and procedures are an effective way to ensure that everyone is on the same page regarding the energy control procedure.

10. Duplicate keys

While duplicate keys may make it easier to remove a lock when an employee has incorrectly left it in place and left the premises, it actually reduces the impact of removing a lock entirely. It makes employees become reliant on duplicate keys and neglect to remove locks according to the standard removal procedure of locks.


An effective lockout/tagout system is essential for all businesses and ensuring that your procedures are working correctly, and employees are following them is one of the biggest factors that businesses fail to act on. Annual audits and reviews are the most effective way to ensure that the lockout/tagout systems you have in place are adequate and working at 100%.

The material provided in this article is for general information purposes only. It is not intended to replace professional/legal advice or substitute government regulations, industry standards, or other requirements specific to any business/activity. While we made sure to provide accurate and reliable information, we make no representation that the details or sources are up-to-date, complete or remain available. Readers should consult with an industrial safety expert, qualified professional, or attorney for any specific concerns and questions.


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Author: Herbert Post

Born in the Philadelphia area and raised in Houston by a family who was predominately employed in heavy manufacturing. Herb took a liking to factory processes and later safety compliance where he has spent the last 13 years facilitating best practices and teaching updated regulations. He is married with two children and a St Bernard named Jose. Herb is a self-described compliance geek. When he isn’t studying safety reports and regulatory interpretations he enjoys racquetball and watching his favorite football team, the Dallas Cowboys.